**Sukut Construction, LLC**

**4010 West Chandler Santa Ana, CA 92704** 

**October, 15 th** 

**2015 U.S. Department of Transportation**  **Docket Management System 1200 New Jersey Ave., SE**  **Washington, DC 20590 Re: Exemption Request Under Section 333 of the FAA**  **Reform Act and Part 11 of the Federal Aviation Regulations**  **Dear Madam, Sir,**
**Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 (the “Reform Act”),**  **and 14 C.F.R. Part 11, Sukut Construction, LLC (“Su kut”), an operator of the eBee Unmanned**  **Aircraft System (“eBee”) seeks an exemption from th e Federal Aviation Regulations (“FARs”)**  **listed below:**

• **14 C.F.R. 21**
• **14 C.F.R. 61.133(a) (b)**
• **14 C.F.R. 91.7(b)**
• **14 C.F.R. 91.119**
• **14 C.F.R. 91.151(a)**

• **14 CFR Subpart E (91.401 - 91.417) The requested exemption would authorize commercial**  **operations using the eBee for mapping and survey applications. These operations will be s**  **ubject to strict operating requirements defined in the eBee user manual (Sukut requests the FAA tre**  **at the eBee training program as proprietary under 14 C.F.R. 11.35(b) and does not include this**  **document in the public docket and conditions defined in the paragraph 3.**  **Sukut Construction is one of Americas leading heavy civil engineering contractors with more**  **than 40 years of proven experience. Sukut Construct ion practices unparalleled earthmoving and**  **civil engineering expertise in over ten areas: Alte rnative Energy, Emergency Response,**  **Flood/Water Control, Grading & Excavation, Land Rem ediation and Landfill Maintenance,**  **Recreation/Resorts Development, Shoring Techniques, Transportation, Underground Utilities,**  **Large Water Systems and Water Infrastructure. Safety at Sukut is at the top of our value list. S**  **afe operations are productive operations, and when work is done safely everyone is a winner. We s**  **trive to provide an environment of open communications where employees can make suggestions**  **for improvement and stop work if an unsafe condition or behavior is observed. With ever**  **yone working as a team it’s like a safety multiplier effect. The ultimate goal of the safety**  **program is to ensure every employee goes home at the end of shift without an injury.**  **Programs that support the safety culture are: • Safety “tailgate” and task training conducted in**  **the field**

**• Safety integrated during the estimating process • Project level risk assessment and hazards analysi**  **s • Pre-task safety planning in the field**  **• Field audits by project staff and safety committe e members**  **• Quarterly Safety Meetings for Foremen, Project an d Executive Management**  **• Innovative training systems targeted at all organ izational levels**  **• Safety Committee input and review for policy deve lopment**  **• Safety recognition and incentive programs • Safety Bulletins to communicate lessons learned a**  **nd reinforce expectations • Environmental planning and compliance on all proj**  **ects • Numerous awards received based on Sukut’s safety**  **achievements World class safety can only be achieved when a “cul**  **ture” has been developed, integrating the values of the company at all levels within the orga**  **nization. This starts at the top with the CEO, and spills down through the Divisions, the Projects**  **, Superintendents, Foremen and their crews.**

**Unmanned Aerial Vehicle (UAV) technology has become a desirable commodity within the**  **capital equipment market. As client demands’ contin ue to evolve, traditional GPS data collection,**  **aerial imagery and lidar lack the resolution, effic iency and accuracy for elite site planning and**  **land resource management. In order to meet these in creasing demands, and safely and efficiently**  **meet the needs of the public, Sukut will utilize th e eBee in its operations. Participating in the**  **exemption process will ensure that Sukut is in comp liance with all current regulations while**  **helping staff safely and responsibly integrate the technology within their operations.** 1. CHARACTERISTICS OF THE AIRCRAFT

**The eBee is a small (37.8 inches wingspan) and ultr a-light (maximum take-off weight of 1.7**  **pounds) platform made of flexible foam that perform s pre-programmed precision aerial mapping**  **missions thanks to the on-board GPS and the related flight management software (eMotion) that**  **allows the operator to plan safely and efficiently a mission in 3D, and then monitor it in real-time.**  **Thanks to the embedded camera, protected by a foam envelope, the eBee takes a collection of**  **high-definition still images that are used later to generate maps and contour lines of the surveyed**  **area. The four main characteristics of the eBee are:** 

**a. Very light weight**  **The eBee is so light that the operator can launch i t by hand and let it land on almost any surface**  **without requiring a parachute or landing net (belly land). Its low impact energy (38 J in case of a**  **controlled emergency landing) also significantly re duces the risk of hazardous situations. Finally,**  **the wings of the eBee are detachable and made of fl exible foam with no sharp or hard edges and**  **almost no internal strengthening structure. b.**  **Electric-powered The eBee is electric powered. A brushless engine te**  **chnology makes it silent and reliable. The propeller is attached with a rubber band to the bod**  **y of the plane so that it can easily flex away in case of contact with any object.** 

**c. Semi-automatic flight**  **The artificial intelligence incorporated within the eBee autopilot system continuously analyzes**  **data from the Inertial Measurement Unit and from th e onboard GPS and takes care of all the**  **aspects of the flight under the supervision of the operator.**  **d. Option for Manual control**  **Additionally, the eBee provides an override capabil ity that allows the operator to take manual**  **actions during the flight (Go to Home, Go Land, Hol d and Resume the mission) and also suspend**  **automated operations and take manual control of the aircraft should it become necessary to**  **respond emergent circumstances, thanks to the remot e controller provided with the system.** 
2. APPLICATIONS
**Sukut intends to utilize the eBee as a data collect ion tool for projects in need of UAV data.**  **As stated, the eBee system can collect real-time, h igh resolution aerial imagery and terrain models**  **that are spatially accurate. Once an area of intere st in flown, images collected during the flight are**  **merged together in a photogrammetry software called Postflight Terra 3D. This software generates**  **dynamic 2D and 3D maps that can easily identify sit e conditions, terrain characteristics and**  **vegetation health. As importantly, Sukut strives to provide excellent**  **product support and training for its**

**customers and employees; it is an integral part of their mission statement. With the approval**  **of this application, the company will be able to co ntinue that level of support and training for**  **eBee clientele. SUKUT’s dedicated training staff wi ll also ensure that customers integrate the**  **system properly and safely into their operation, an d the US airspace.**  **Below are the specific items the technology will be applied to:** 

• **Topography characteristics and analysis**

• **Volumetric measurement calculations**

• **Slope analysis**

• **Vegetation health**

• **Vegetation species identification**

• **Hazard evaluation**

• **Project design evaluation**

• **Natural resource identification**

• **Customer training**

• **Employee training**
3. APPLICABLE LEGAL STANDARD UNDER SECTION 333
**a. Airworthiness assessment of the eBee**
**Sukut notes that the airworthiness of the eBee has already been demonstrated for different projects**  **in the United States, involving state/federal agenc ies or universities (among others the New Mexico**  **State University: https://newscenter.nmsu.edu/Articles/view/10208/nm**  **su-uas-flight-test-center conducts-ebee-airworthiness-assessment,**  **and the USACE New Orleans, who coordinated with th e**  **Department of Army and the FAA to obtain all author izations required in order to operate the eBee**  **UAS). Moreover the eBee already received 15 Exempti ons from the FAA.**  **SenseFly also obtained flight approvals for the eBe e (delivered by national civil aviation**  **authorities) in many countries, among others:**

• **Switzerland (flight approval for VLOS operations)**

• **Canada (flight approval for VLOS operations)**
• **Australia (flight approval for VLOS operations)**
• **France (flight approval for Extended-VLOS operation s)** 
• **Germany (flight approval for VLOS operations)**
• **United Kingdom (flight approval for VLOS operations )** 
• **Norway (flight approval for VLOS operations)**
• **Sweden (flight approval for VLOS operations)**

• **Denmark (flight approval for VLOS operations)**
**b. Operating requirements Grant of the exemption to Sukut Construction, LLC f**  **or the eBee will be subject to the following operating conditions:** 

• **1. Operations authorized by this grant of exemption are limited to the SenseFly eBee when** **weighing less than 55 pounds including payload. Pro posed operations of any other** 

**aircraft will require a new petition or a petition to amend this exemption.** 

• **2. Operations for the purpose of closed-set motion picture and television filming are not**  **permitted.**

• **3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The**  **exemption holder may use either groundspeed or cali brated airspeed to determine**  **compliance with the 87 knot speed restriction. In n o case will the UA be operated at**  **airspeeds greater than the maximum UA operating air speed recommended by the aircraft**  **manufacturer.**

• **4. The UA must be operated at an altitude of no mor e than 400 feet above ground level**  **(AGL). Altitude must be reported in feet AGL.**

• **5. The UA must be operated within visual line of si ght (VLOS) of the PIC at all times.**  **This requires the PIC to be able to use human visio n unaided by any device other than**  **corrective lenses, as specified on the PIC’s FAA-is sued airman medical certificate or**  **U.S. driver’s license.**

• **6. All operations must utilize a visual observer (V O). The UA must be operated within**  **the visual line of sight (VLOS) of the PIC and VO a t all times. The VO may be used to**  **satisfy the VLOS requirement as long as the PIC alw ays maintains VLOS capability. The**  **VO and PIC must be able to communicate verbally at all times; electronic messaging or**  **texting is not permitted during flight operations. The PIC must be designated before the**  **flight and cannot transfer his or her designation f or the duration of the flight. The PIC**  **must ensure that the VO can perform the duties requ ired of the VO.** 

• **7. This exemption and all documents needed to opera te the UAS and conduct its**  **operations in accordance with the conditions and li mitations stated in this grant of**  **exemption, are hereinafter referred to as the opera ting documents. The operating**  **documents must be accessible during UAS operations and made available to the**  **Administrator upon request. If a discrepancy exists between the conditions and limitations**  **in this exemption and the procedures outlined in th e operating documents, the conditions**  **and limitations herein take precedence and must be followed. Otherwise, the operator**  **must follow the procedures as outlined in its opera ting documents. The operator may**  **update or revise its operating documents. It is the operator’s responsibility to track such**  **revisions and present updated and revised documents to the Administrator or any law**  **enforcement official upon request. The operator mus t also present updated and revised**  **documents if it petitions for extension or amendmen t to this grant of exemption. If the**  **operator determines that any update or revision wou ld affect the basis upon which the**  **FAA granted this exemption, then the operator must petition for an amendment to its grant**  **of exemption. The FAA’s UAS Integration Office (AFS -80) may be contacted if questions**  **arise regarding updates or revisions to the operati ng documents.** 

• **8. Any UAS that has undergone maintenance or altera tions that affect the UAS operation**  **or flight characteristics, e.g. replacement of a fl ight critical component, must undergo a**  **functional test flight prior to conducting further operations under this exemption.**  **Functional test flights may only be conducted by a PIC with a VO and must remain at**  **least 500 feet from other people. The functional te st flight must be conducted in such a**  **manner so as to not pose an undue hazard to persons and property.** • **9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is** 

**in a condition for safe operation.**

• **10. Prior to each flight, the PIC must conduct a pr e-flight inspection and determine the**  **UAS is in a condition for safe flight. The pre-flig ht inspection must account for all**  **potential discrepancies, e.g. inoperable components , items, or equipment. If the**  **inspection reveals a condition that affects the saf e operation of the UAS, the aircraft is**  **prohibited from operating until the necessary maint enance has been performed and the**  **UAS is found to be in a condition for safe flight.**

• **11. The operator must follow the UAS manufacturer’s maintenance; overhaul,**  **replacement, inspection, and life limit requirement s for the aircraft and aircraft**  **components.**

• **12. Each UAS operated under this exemption must com ply with all manufacturer safety**  **bulletins.**

• **13. Under this grant of exemption, a PIC must hold either an airline transport, commercial,**  **private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman**  **medical certificate or a valid U.S. driver’s licens e issued by a state, the District of**  **Colombia, Puerto Rico, a territory, a possession, o r the Federal government. The PIC must**  **also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which**  **the PIC is rated on his or her pilot certificate.**

• **14. The operator may not permit any PIC to operate unless the PIC demonstrates the**  **ability to safely operate the UAS in a manner consi stent with how the UAS will be**  **operated under this exemption, including evasive an d emergency maneuvers and**  **maintaining appropriate distances from persons, ves sels, vehicles and structures. PIC**  **qualification flight hours and currency must be log ged in a manner consistent with 14**  **CFR § 61.51(b). Flights for the purposes of trainin g the operator’s PICs and VOs**  **(training, proficiency, and experience-building) an d determining the PIC’s ability to**  **safely operate the UAS in a manner consistent with how the UAS will be operated under**  **this exemption are permitted under the terms of thi s exemption. However, training**  **operations may only be conducted during dedicated t raining sessions. During training,**  **proficiency, and experience-building flights, all p ersons not essential for flight operations**  **are considered nonparticipants, and the PIC must op erate the UA with appropriate**  **distance from nonparticipants in accordance with 14 CFR § 91.119.** 

• **15. UAS operations may not be conducted during nigh t, as defined in 14 CFR § 1.1. All**  **operations must be conducted under visual meteorolo gical conditions (VMC). Flights**  **under special visual flight rules (SVFR) are not au thorized.** 

• **16. The UA may not operate within 5 nautical miles of an airport reference point (ARP)**  **as denoted in the current FAA Airport/Facility Dire ctory (AFD) or for airports not**  **denoted with an ARP, the center of the airport symb ol as denoted on the current FAA**  **published aeronautical chart, unless a letter of ag reement with that airport’s management**  **is obtained or otherwise permitted by a COA issued to the exemption holder. The letter**  **of agreement with the airport management must be ma de available to the Administrator**  **or any law enforcement official upon request.**

• **17. The UA may not be operated less than 500 feet b elow or less than 2,000 feet**  **horizontally from a cloud or when visibility is les s than 3 statute miles from the PIC.** • **18. If the UAS loses communications or loses its GP S signal, the UA must return to a** 

**predetermined location within the private or contro lled-access property.** 

• **19. The PIC must abort the flight in the event of u npredicted obstacles or emergencies.** 

• **20. The PIC is prohibited from beginning a flight u nless (considering wind and forecast**  **weather conditions) there is enough available power for the UA to conduct the intended**  **operation and to operate after that for at least fi ve minutes or with the reserve power**  **recommended by the manufacturer if greater.**

• **21. Air Traffic Organization (ATO) Certificate of W aiver or Authorization (COA). All**  **operations shall be conducted in accordance with an ATO-issued COA. The exemption**  **holder may apply for a new or amended COA if it int ends to conduct operations that**  **cannot be conducted under the terms of the attached COA.** 

• **22. All aircraft operated in accordance with this e xemption must be identified by serial**  **number, registered in accordance with 14 CFR part 4 7, and have identification (N**  **Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as**  **large as practicable.** 

### •
• **23. Documents used by the operator to ensure the sa fe operation and flight of the UAS**  **and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the**  **PIC at the Ground Control Station of the UAS any ti me the aircraft is operating. These**  **documents must be made available to the Administrat or or any law enforcement official**  **upon request.**

• **24. The UA must remain clear and give way to all ma nned aviation operations and**  **activities at all times.**

• **25. The UAS may not be operated by the PIC from any moving device or vehicle.** 

• **26. All Flight operations must be conducted at leas t 500 feet from all nonparticipating**  **persons, vessels, vehicles, and structures unless:**
• **a. Barriers or structures are present that sufficie ntly protect nonparticipating persons from**  **the UA and/or debris in the event of an accident. T he operator must ensure that**  **nonparticipating persons remain under such protecti on. If a situation arises where**  **nonparticipating persons leave such protection and are within 500 feet of the UA, flight**  **operations must cease immediately in a manner ensur ing the safety of nonparticipating**  **persons; and**
• **b. The owner/controller of any vessels, vehicles or structures has granted permission for**  **operating closer to those objects and the PIC has m ade a safety assessment of the risk of**  **operating closer to those objects and determined th at it does not present an undue hazard.**  **The PIC, VO, operator trainees or essential persons are not considered nonparticipating**  **persons under this exemption.**

• **27. All operations shall be conducted over private or controlled-access property with**  **permission from the property owner/controller or au thorized representative. Permission**  **from property owner/controller or authorized repres entative will be obtained for each**  **flight to be conducted.** **28. Any incident, accident, or flight operation tha t transgresses the lateral or vertical** 

**boundaries of the operational area as defined by th e applicable COA must be reported to**  **the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported**  **to the National Transportation Safety Board (NTSB) per instructions contained on the**  **NTSB Web site: www.ntsb.gov.** 
3. CONCLUSION **Overall, UAV technology offers a more efficient, co st-effective data collection method to the**  **mining, construction and agricultural industries. U tilizing the eBee will allow Sukut to provide its**  **customers a service and platform that will save mon ey and increase workflow efficiency.**  **Furthermore, the unmanned aspect decreases the risk of placing employees in hazardous**  **conditions often required by traditional data colle ction devices.**  **Sukut, in association with SenseFly, who has experi ence with safe integration of unmanned**  **aircraft in the National airspace, has hopefully pr ovided an adequate justification for the grant of**  **the exemption allowing use of the eBee for data col lection.**  **Please do not hesitate to contact me if you have an y questions.** 

**Yours sincerely,**

**Matt Eklund, PE GPS Program Manager**  **Sukut Construction, LLC meklund@sukut.com**  **714.540.5351 Have a sport or recreational pilot license (at leas**  **t) and have successfully passed a manufacturer’s**

ANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTIO N **SUKUT requests an exemption from the following regu lations as well as any additional**  **regulations that may technically apply to the opera tion of the eBee:**  14 C.F.R. Part 21, Subpart H: Airworthiness Certifi cates 14 CFR § 91.203(a)(1) **Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H,**  **entitled Airworthiness Certificates, establishes th e procedural requirements for the issuance of**  **airworthiness certificates as required by FAR § 91. 203(a). Given the size of the eBee, its very**  **light weight (the maximum take-off weight is 1.7 po unds) and the limited operating area**  **associated with its utilization, it is unnecessary to go through the certificate of airworthiness**  **process under Part 21 Subpart H in order to achieve or exceed current safety levels.**  **Such an exemption meets the requirements of an equi valent level of safety under Part 11 and**  **Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act**  **both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate,**  **upon consideration of the size, weight, speed, oper ational capability, and proximity to airports**  **and populated areas of the UAS involved. An analysi s of these different criteria demonstrates that**  **the eBee operated without an airworthiness certific ate, under the conditions proposed in that**  **exemption, will be at least as safe, or safer, than a conventional aircraft with an airworthiness**  **certificate. A proprietary risk assessment for oper ations with the eBee, which demonstrates that**  **assertion, is also being submitted to the FAA as pa rt of this application. SUKUT requests the**  **FAA treat the eBee risk assessment as proprietary u nder 14 C.F.R. 11.35(b) and not include this**  **document in the public docket.** 14 C.F.R. § 61.3: Requirements for certificates, ra tings and authorizations 14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pil ot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitat ions **The regulation provides that no person may serve as a required pilot flight crewmember of a civil**  **aircraft of the United States, unless that person: (1) Has a pilot certificate or special purpose pilo**  **t authorization issued under this part in that person's physical possession or readily accessible**  **in the aircraft when exercising the privileges of that pilot certificate or authorization. However, w**  **hen the aircraft is operated within a foreign country, a pilot license issued by that country may**  **be used. The regulation provides also that no person that ho**  **lds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Su**  **bparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with**  **any business or employment if: (1)**  **The flight is only incidental to that business or e mployment;**  **(2) The aircraft does not carry passengers or property**  **for compensation or hire. Given the safety features of the eBee and the fact**  **that the missions are pre-programmed and monitored in real-time with a specific flight manag**  **ement software (eMotion), SenseFly proposes that operators of the eBee should not be required t**  **o hold a commercial pilot certification. Instead,**

**operators should be required to: training program for the eBee.**  14 C.F.R. § 91.7(a): Civil aircraft airworthiness **This regulation requires that no person may operate a civil aircraft unless it is in airworthy**  **condition. Should the exemption be granted allowing commercial operation of the eBee without**  **an airworthiness certificate, no standard will exis t for airworthiness of the eBee. Given the size of**  **the aircraft and the previous airworthiness assessm ents given to the eBee, among others:** 
 **New Mexico State University: https://newscenter.nmsu.edu/Articles/view/10208/nm**  **su uas-flight-test-center-conducts-ebee-airworthiness-**  **assessment**
 **USACE New Orleans, who coordinated with the Departm ent of Army and the FAA to**  **obtain all authorizations required in order to oper ate the eBee UAS for levee system**  **monitoring, documentation of construction progress, and extensive oblique photography**  **of USACE structures & activities An equivalent level of safety will be achieved by i**  **nsuring compliance with the SenseFly manuals prior to each flight.**  14 CFR § 91.119: Minimum Safe Altitudes **The regulation provides that over sparsely populate d areas the aircraft cannot be operated closer**  **than 500 feet to any person, vessel, vehicle, or st ructure. Since the aircraft will be operating at a**  **maximum of 400 feet AGL, the eBee cannot comply wit h this requirement.**  **The equivalent level of safety will be achieved bec ause the eBee will only fly over private**  **property with the permission of the landowner. The operator will define before every flight a**  **working area radius and a flight area ceiling, prev enting the eBee to go beyond the flight area.**  **The landowner and the persons who may be on the gro und in the flight area will be briefed of the**  **expected route of flight and the associated risks t o persons and property on the ground. Due to the**  **small size of the eBee and the material with which the eBee is built, the hazard to persons,**  **vessels, vehicles, and structures is not comparable to manned aircraft and should be considered in**  **granting the exemption. Moreover, the aircraft will not be operated over co**  **ngested areas, or over any open-air assembly of persons. The aircraft will be operated at an alt**  **itude allowing, if a power unit fails, an emergency landing without undue hazard to persons o**  **r property on the surface.** 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions **The regulation provides that no person may begin a flight in an airplane under day-VFR**  **conditions unless there is enough fuel to fly to th e first point of intended landing and to fly after**  **that for at least 30 minutes. Given the area of operation for the eBee, SUKUT bel**  **ieves that an equivalent level of safety is already achieved with the specific procedure preven**  **ting the eBee to accept a take-off order is the battery level is below a given value. Moreover, Sen**  **seFly has integrated “low” and “critical” battery level warning, and implemented a “return to**  **Home” (and “Go Land”) actions in these situations.** 14 CFR Subpart E (91.401 - 91.417) - Maintenance, P reventive Maintenance,

and Alterations **The regulation provides that the operator is primar ily responsible for maintaining the aircraft in an**  **airworthy condition, including compliance with Part s 39 and 43. Paragraphs 91.407 and 91.409**  **require that the aircraft be "approved for return t o service by a person authorized under 43.7" after**  **maintenance and inspection. Section 91.409(a)(2) re quires an annual inspection for the issuance of**  **an airworthiness certificate. Section 91.417(a) req uires the owner or operator to keep records**  **showing certain maintenance work that has been acco mplished by certificated mechanics, under**  **Part 43, or licensed pilots and records of approval of the aircraft for return to service.**  **SUKUT proposes that the maintenance of the eBee wil l be accomplished by the owner/operator**  **according to the maintenance manual, provided by Se nseFly. SUKUT requests the FAA treat the**  **eBee training program as proprietary under 14 C.F.R . 11.35(b) and not include this document in**  **the public docket. An equivalent level of safety will be achieved beca**  **use the eBee is small in size, it is not a complex mechanical device, it will carry no externa**  **l payload, and it will operate only in restricted predetermined areas. Moreover, the operator is the**  **person most familiar with the aircraft and is best suited to maintain the aircraft in an airworth**  **y condition and to ensure an equivalent level of safety. Finally, before every flight, the eBee runs**  **automatically a sequence of pre-flight tests to make sure that every sensor and every critical part**  **is running properly. If a problem is detected, the eBee will not be able to be switched-on, and a**  **message error is displayed on the main screen of the flight management software. The operator can**  **then refer to the maintenance manual to troubleshoot this issue. Several parts of the eBee**  **are easily interchangeable (propellers, wings), which allows the operator to make sure the wings an**  **d propulsion system are always airworthy when a mission is initiated.**